ORDER AFFIRMING THE COMMISSIONER'S DECISION
JEROME T. KEARNEY, Magistrate Judge.
Carolyn E. Wilson seeks judicial review of the denial of her application for disability insurance benefits and supplemental security income. In the past, Wilson worked as a certified nursing assistant.1 She last worked as a housekeeper for Wal-Mart.2 She maintains she lost that job because she missed too many work days due to migraines and her son's illness.3 She has not sought work since that time.
When she applied for disability benefits, Wilson alleged disability beginning in 2002 — at age 25 — but her attorney amended her onset date to July 1, 2008, because she worked until June 2008.4 She based disability on night blindness, a cataract in the right eye, migraine headaches, and pain in her hips and knees.5 Wilson was 31 years old on her amended onset date.
The Commissioner's decision. After considering the application, the Commissioner's ALJ determined that although Wilson had severe impairments — ankle pain, right knee pain, back pain, depression, migraines, obesity, and carpal tunnel syndrome6 — Wilson could do some sedentary work.7 Because a vocational expert identified available work, the ALJ determined Wilson was not disabled under the Social Security Act and denied the application.8
After the Commissioner's Appeals Council denied a request for review,9 the ALJ's decision became a final decision for judicial review.10 Wilson filed this case to challenge the decision. In reviewing the decision, the court must determine whether substantial evidence supports the decision and whether the ALJ made a legal error.11 "Substantial evidence `means such relevant evidence as a reasonable mind might accept as adequate to support a conclusion.'"12
Credibility. Wilson challenges the ALJ's assessment of her credibility.13 She maintains the ALJ failed to explain how the Polaski factors made her more or less credible or why the points he noted detracted from credibility. She contends the mentioned points are consistent with disability.
An ALJ has a duty to assess the claimant's credibility.14 To assess Wilson's credibility, the ALJ followed the required two-step process15 and considered the Polaski factors.16 The ALJ is not required to methodically discuss each Polaski factor, so long as the ALJ acknowledged and examined those considerations before discounting the claimant's subjective complaints.17 Thus, the question before the court is whether substantial evidence supports the ALJ's credibility assessment.18
Substantial evidence supports the ALJ's credibility assessment because Wilson's allegations were inconsistent with the record as a whole. "Subjective complaints may be discounted if there are inconsistencies in the evidence as a whole."19 Wilson based disability in substantial part on migraine headaches, but medical evidence indicated her migraines improved with daily preventive medication and migraine pain relievers. After her last medical checkup, her PCP characterized her migraines as "stable."20 This characterization contradicted Wilson's testimony five days later that migraines prevented her from working.21 The inconsistency between the PCP's characterization of Wilson's migraines and her testimony weighed against her credibility. A reasonable mind would accept the evidence as adequate to show that Wilson over-stated limitation from migraines.
The medical evidence was also inconsistent with complaints of disabling pain in the back, ankles, and knees. Radiographic imaging showed nothing supporting such severity. A June 2009 MRI of the lumbar spine showed "very mild" degenerative disk disease, without significant canal or neuroforaminal stenosis.22 The characterization "very mild" and the absence of stenosis contradicted the allegation of disabling back pain.23
Imaging of the left ankle was negative;24 no physician ordered imaging of the right ankle. Imaging of the problematic knee — the right knee — did not substantiate disabling pain.25 Wilson's doctor treated the knee by prescribing physicial therapy.26 This conservative treatment indicated that the pain could be managed with treatment.27 The record substantiates some degree of pain,28 but not disabling pain. A reasonable mind would accept the inconsistency between Wilson's allegations and the objective medical evidence as adequate to show Wilson over-stated her pain and limitation. Thus, substantial evidence supports the ALJ's credibility assessment.
Sedentary work. Wilson challenges the determination that she can do sedentary work. She complains that the ALJ did not account for carpal tunnel syndrome or identify anything contradicting her allegation about a limited ability to sit.29 Relying on these omissions, she maintains the hypothetical question failed to capture all of her impairments.30 She maintains the ALJ's decision is not supported by substantial evidence.
For substantial evidence to exist, a reasonable mind must find the evidence adequate to show Wilson can do sedentary work. Sedentary work "involves lifting no more than 10 pounds at a time and occasionally lifting or carrying articles like docket files, ledgers, and small tools."31 Sedentary work "represents a significantly restricted range of work. Individuals who are limited to no more than sedentary work by their medical impairments have very serious functional limitations."32
A reasonable mind would accept medical treatment notes as adequate to show Wilson can do some sedentary work. Wilson's PCP characterized her migraines as stable.33 Radiographic imaging of the back showed "[v]ery mild degenerative disk disease" and "[n]o significant canal or neuroforaminal stenosis."34 Orthopedic examination of the ankles demonstrated "full active/passive range of motion with mild discomfort upon range of motion testing," no swelling, and no defect in the Achilles tendons.35 Imaging of the knees showed no fracture, dislocation, degenerative disk disease, bone destruction, or bone/cartilage fragments.36 Orthopedic examination of the right knee showed no swelling, problem with extension, or meniscus tear; the examination revealed tenderness in the front of the knee.37 A subsequent MRI showed a fluid-filled cyst behind the right knee.38 Such cysts may cause pain and swelling, but treating the cyst with corticosteroid medication, fluid drainage, or physical therapy usually provides relief.39 A reasonable mind would accept this evidence as adequate to support sedentary work.
The evidence of carpal tunnel syndrome does not preclude sedentary work. An August 2007 nerve conduction study confirmed "mild" carpal tunnel syndrome in both hands,40 but Wilson contemporaneously demonstrated the ability to hold a pen and write, touch fingertips to palm, oppose thumb to fingers, and pick up a coin.41 This demonstration contradicted significant limitation. Moreover, Wilson did not complain about carpal tunnel syndrome during her February 2011 orthopedic examination.42 The failure to complain indicates carpal tunnel syndrome does not significantly impact the ability to work. Two weeks prior to her orthopedic examination, Wilson told her PCP that wrist splints and pain relievers kept her pain at bay.43 The PCP characterized carpal tunnel syndrome as "reasonably stable."44
Wilson's weight45 poses perhaps the most significant functional limitation. Her weight corresponds to a body mass indicator (BMI) of 50; a BMI over 30 is considered obese. Because obesity can limit function,46 an ALJ must consider obesity in determining a claimant's ability to work. The ALJ accounted for obesity and reduced Wilson's ability to work to sedentary.47 The ALJ reduced sedentary work — based on a mental diagnostic evaluation48 — and required work in which interpersonal contact is incidental to the work performed; the complexity of tasks is learned and performed by rote, few variables, little judgment; and supervision required is simple, direct and concrete.
The ALJ incorporated these impairments into a hypothetical question and asked a vocational expert about available work. A hypothetical question is sufficient if it captures the concrete consequences of the claimant's deficiencies.49 The ALJ's restrictions captured the concrete consequences of Wilson's deficiencies; in particular, (1) sedentary work due to obesity and mild to moderate pain, and (2) work in which interpersonal contact is incidental to the work performed; the complexity of tasks is learned and performed by rote, few variables, little judgment; and supervision required is simple, direct and concrete.50 The omission of carpal tunnel syndrome and limited sitting flowed from the medical evidence and the evaluation of credibility. When asked about sitting, standing, and walking in April 2011, Wilson identified problems with standing and walking, but not sitting.51 Even with the ALJ's restrictions, the vocational expert identified available work.52 If work exists that the claimant can do, she is not disabled under the Social Security Act.53
Conclusion. Substantial evidence supported the ALJ's decision denying Wilson's application. The ALJ made no legal error. For these reasons, the court DENIES Wilson's request for relief (docket entry # 2) and AFFIRMS the decision denying the application.
It is so ordered.